Humberside PEEL 2018
How legitimately does the force treat the public and its workforce?
Humberside Police is good at treating the public fairly.
The force communicates well with the public. We were pleased that it has improved the way it records and understands use of force. It has improved how it uses stop and search. But it could monitor both of these better.
The force has a good culture of ethical and lawful workforce behaviour. Leaders make sure the workforce know the force’s values. The force now has an ethics committee. It should tell the workforce how to use the committee to discuss ethical dilemmas. Humberside Police knows the corruption risks it faces and has plans to deal with them.
Humberside Police is good at treating its workforce fairly.
To what extent does the force treat all of the people it serves with fairness and respect?
Areas for improvement
- The force should ensure that, in relation to stop and search:
- all relevant officers and supervisors understand what constitutes reasonable grounds and how to record them;
- it monitors a comprehensive set of data to enhance its understanding of fair and effective use of the power; and
- effective external scrutiny takes place.
We set out our detailed findings below. These are the basis for our judgment of the force’s performance in this area.
Treating people fairly and respectfully
We found Humberside Police had a good understanding of the importance of engaging with its communities and treating the people it serves with fairness and respect.
The force’s leaders have a strong focus on communicating with the public. The use of media is more positive. Chief officers and heads of department lead this by providing a public face in response to continuing incidents and campaigns. When needed they also demonstrate the ethical standards of the force by recognising when things haven’t gone well. The force’s plan on a page highlights that understanding the community’s needs is a priority, through communicating, protecting people and the force’s culture, values and behaviours. The force has remained loyal to a neighbourhood policing style and has 81 wards, each with an identified officer or a PCSO. Social media use has grown, but the force needs to be mindful that this is a two-way process: some officers told us that monitoring and responses to social media interactions could be better.
The chief constable took the important decision to recognise the identity of Humberside and reinstate two distinct policing areas of North Bank and South Bank. This realigns the positioning of policing in the geographical communities. We heard of chief officers taking part in ‘walk in my shoes’ community days, going out to some harder-to-reach communities and events. We spoke to officers and staff who said that this type of leadership is instilling them with confidence again.
The force uses ‘mystery shoppers’ to test systems for public interactions (for example, enquiry desks, 101 calls, complaints) as this affects public confidence. It then makes changes in response to any problems identified. The force told us about one example of them making changes, which related to someone reporting a hate crime at an enquiry desk. The force identified that enquiry-desk staff needed additional training to improve their knowledge of hate crime, to help them respond better to this type of incident in the future. It then provided this training to all relevant staff.
We found numerous communication channels in use and work in progress to engage with communities that are harder to reach, such as in the Beverley Road area of Hull. This has a high number of areas of deprivation and high demand for police services. The aim of this project is for the force to have a greater understanding of what it is like to live there, so that it can identify the issues and solve problems. This will involve about 9,500 homes. The force has plans to expand this project to visit and survey over 400,000 homes in Humberside. In this way, the force will be engaging with as many residents as possible to inform future policing.
The police community teams work with community cohesion officers. These officers are responsible for identifying new and emerging groups in the community, such as people who have recently migrated to the area. Their aim is to ‘myth bust’ any perceptions these new arrivals may have of the police. Once they have created good links with the community, they introduce them to the police officers and PCSOs. This has recently occurred in relation to a new Somali group of residents.
We found evidence of community engagement influencing neighbourhood-policing activity. Local policing teams hold surgeries and use ‘cuppa with a copper’ events. They provide social media updates and information about local priorities is on the force website. Residents can also email local policing teams. The force has introduced a new ‘my community alert’ system that enables residents, businesses and community groups to find out what is happening in their local area. They register and receive real-time messages about incidents happening in their neighbourhood that may affect them.
Last year we said the force should ensure its workforce understands unconscious bias. This year we found that this has improved. We spoke to members of the workforce and found consistently good understanding and explanation of unconscious bias across the force. The force has provided specific training to some neighbourhood policing officers, to give them a better understanding of people who are travellers, Roma, refugees or homeless. This will equip them better in their community roles.
At the time of our inspection, we found that the force was focusing general communications training at new recruits. Other officers receive communications training as part of their personal safety training, but this focuses on diffusion of tension at incidents. The force now needs to consider how to improve the wider communication skills for all officers.
In our 2017 legitimacy report, we identified that the force should ensure that it effectively monitors data on the use of force to ensure that it uses force fairly and proportionately. This year we found a generally good understanding in the officers we spoke to on use of force and the need to record it. The force provides personal safety training to all officers and this includes special constables. This incorporates instruction on how to record the use of force.
Humberside Police complies with the National Police Chiefs’ Council recording requirements for the use of force. The force understands it still has some areas to improve, such as use of force in custody and ensuring officers record compliant handcuffing. We spoke to some supervisors who confirmed that some officers are reluctant to use compliant handcuffing, as they want to avoid having to record it. The force needs to monitor this for its officers’ safety and to understand when and why officers use this equipment.
Governance processes are in place to supervise and dip-sample the forms that officers must submit regarding their use of force. All such forms go to a sergeant in the first instance to assess. If satisfactory, the sergeant enters on the database and further dip-sampling then takes place. Supervisors return any forms that are insufficient in detail and rationale to the officer, with feedback on the areas of justification and evidence that are required. The force cannot be completely confident that officers and/or sergeants are submitting all use of force forms. The force also recognises it needs to develop its use of force recording from custody records. The professional standards department (PSD) provides scrutiny in terms of trends and complaint monitoring. The force is now using body-worn video camera footage to investigate and resolve complaints.
Humberside Police has a use of force scrutiny panel. This panel has clear terms of reference and is administered by the PCC’s office. Paid volunteers (members of the diversity panel) make up the main external scrutiny panel, with specific force leads invited as guests as and when required. The meeting is held in two parts: the first part involves an open discussion of use of force forms, led by the PCC’s office diversity lead, and only includes external scrutiny members. Part two of the meeting is chaired by a chief inspector from the force’s specialist operations department. Panel members examine a range of data, including use of force in a mental health setting. The development of the use of body-worn video cameras across the force should provide a good opportunity to expand monitoring, as the panel will be able to examine footage from incidents. The force lead for use of force explained it is conducting further research into the use of force on BAME people. Data shows that officers are more likely to use force on people from a BAME background. The force would like to understand why this is, so that it can take action to address it if necessary.
During our inspection we attended the annual trend analysis meeting, which examined use of force data. We found good attendance from relevant departments and this included a wellbeing representative. The panel discussed specific incidents, and the PSD provided detail on reviews of body-worn video camera footage in complaints. The panel examined data that included: volumes of use of force; types of force used; gender of subject; ethnicity of subject; reasons for use; and impact factors. The force could enhance this data further if it included the subject’s age, any injuries to subjects, and details of any disproportionality and officers or teams that use force more frequently.
We recognise the progress that Humberside Police has made in monitoring the use of force. Inclusion of further data at this forum would enrich the force’s understanding of how it uses force fairly and proportionately. The force informed us it is able to access this data. It should continue to encourage these enhancements.
The independent advisory group, which consists of members from a range of communities and diverse groups within Humberside, provides further advice to the force. An example of their involvement was their consultation and advice about the introduction of spit guards by the force. The force is engaging with neighbourhood teams to make contacts within harder-to-reach communities, to improve the robustness of its external scrutiny.
The force also publishes data on the use of force on its public website. We examined this and found it was easy to understand and covered handcuffing, dog bites, restraints, baton use, tactical communications, spit guards, Taser, firearms and incapacitant spray. The force had broken this data down into gender, ethnicity, reasons, impact and how many uses resulted in complaint and assault on officers.
Using stop and search powers
In our 2017 legitimacy report, we said that the force should ensure that officers and supervisors understand what constitutes reasonable grounds for stop and search and how to record them. During this year’s inspection, we found that the force has an extensive training package for stop and search. Officers we spoke to had received some stop and search training and understood the importance of using powers correctly. All officers we spoke to clearly understand what unconscious bias means. The Special Constabulary senior officer confirmed that special constables receive this training.
The force has extended stop and search training to senior officers who chair tasking processes. This increases their understanding of stop and search powers, and their legality when directing operational activity for their officers. This is positive to see. We did though detect a lack of confidence among officers to use stop and search. The force is aware of this.
We reviewed a representative sample of 337 stop and search records to assess the reasonableness of the recorded grounds. We found that 81 percent had reasonable grounds recorded. Our assessment is based on the grounds recorded on the record by the searching officer and not the grounds that existed at the time of the search.
We found the force to be very open to learning, to encourage improvements in completion and monitoring processes for stop and search. It has used peer reviews from another force and advice from the College of Policing to understand stop and search use and accuracy. The force identified it needed to make improvements to address four main areas:
- vague grounds;
- grounds containing the words ‘intelligence suggests’;
- grounds containing the word ‘suspicious’, with no further evidence; and
- grounds containing reference to third-party information such as CCTV reports.
The force has made a video outlining good and bad practice. This gives officers and staff examples that clearly explain lawful grounds of stop and search. The force has carried out further audits since it introduced the video. It considers there has been a significant improvement in the detail and lawfulness provided on stop search records. A supervisory officer now audits every record, with further dip-sampling at inspector and superintendent level. They provide feedback to officers but should extend this to include feedback to their supervisors.
During our inspection we viewed another 20 records. We saw some improvements with officers recording more information to justify the use of stop and search powers. But some records still didn’t have reasonable grounds recorded. The force should continue to encourage these improvements.
Humberside Police stated it examines data that can be broken down to team and individual level, ethnicity of subject, grounds of the search, and outcome of search. The force could further enhance this. It tried to commission further analysis on the stop and search of people from a BAME background, for reassurance about the fairness of its stop and search practices. But the available data was insufficient as a sample to draw any analytical conclusions. The legitimacy board monitors the use of stop and search and the deputy chief constable chairs this board. Supervisors check all stop and search forms and provide feedback to officers on any errors. The assistant chief constable and superintendent responsible for stop and search carry out more analysis monthly and report this to the legitimacy board.
Humberside Police has attempted to engage with some harder-to-reach communities on the issue of stop and search, but its initial findings didn’t return any specific concerns. The force provides opportunities for members of the public to see stop and search taking place, through its ride-along scheme. Members of the PCC’s diversity panel provide external monitoring of stop and search, which is positive. Best practice would be for the chair of this panel to be independent. The force has introduced body-worn video camera footage, and this will provide opportunities for enhanced scrutiny and feedback that the force should develop. We couldn’t see how this forum challenges the force, and the force doesn’t make use of its independent advisory group or local community groups for monitoring stop and search. The force would benefit from satisfying itself it is receiving enough external challenge on stop and search and adopt the best practice of having independent chairpersons.
The force publishes stop and search data on its website. The force could enhance this website data by bringing it up to date (our inspection was October 2018, but data published was to April 2018).
In our 2017 legitimacy report, we recommended that all forces should:
- monitor and analyse comprehensive stop and search data to understand reasons for disparities;
- take action on those; and
- publish the analysis and the action by July 2018.
We found that the force has complied with some of this recommendation. But it doesn’t identify the extent to which find rates differ between:
- people from different ethnicities; and
- different types of searches (including separate identification of find rates for drug possession and supply-type offences).
The force doesn’t identify the prevalence of possession-only drug searches, and the extent to which these align with local or force-level priorities. It publishes a brief explanation of the disproportionality rate, but hasn’t published any analysis supporting this explanation.Summary for question 1
How well does the force ensure that its workforce behaves ethically and lawfully?
Areas for improvement
- The force should ensure that its counter-corruption unit:
- has enough capability and capacity to counter corruption effectively and proactively; and
- can fully monitor all of its computer systems, including mobile data, to proactively identify data breaches, protect the force’s data and identify computer misuse.
- The force should ensure it refers all applicable cases of corruption to the Independent Office for Police Conduct and records these from the outset.
We set out our detailed findings below. These are the basis for our judgment of the force’s performance in this area.
Maintaining an ethical culture
Humberside Police has a good approach to developing and maintaining an ethical culture. There has been a refresh of the code of ethics across the force, with its priorities clearly displaying that the “foundation of everything is our culture, values and behaviours”.
We found that the values and behaviours of the force are clearly displayed throughout the police premises we visited. They are also weaved into the force’s plan on a page. Workforce members we spoke to are aware of the plan. They told us they would raise any ethical issues they had with immediate supervisors. But ethical conversations did not appear to be a standardised process.
The chief constable holds pledge events with supervisors. These are popular and supportive as they build a wider-force team commitment. Members of the workforce we spoke to said that chief officers are visible within the force, visiting police stations, holding open-voice forums and engaging with the workforce.
In 2017, we suggested the force should review the need to have an external ethics committee, to ensure that it has independent scrutiny of its decisions and a place to discuss ethical dilemmas faced by the force. This year we found there is now a joint force and office of the PCC (OPCC) ethics meeting. The OPCC administers this and has identified an independent chair to lead the meeting. However, we found that those we spoke to did not know much about the committee and did not know how to raise issues for it to consider. The force would benefit from clarifying this to encourage its use.
We found that the force and the management within the PSD have a strong focus on learning and prevention rather than a blame culture. They aim to be progressive in making the PSD accessible, to gain the confidence of the workforce. There is an organisational learning board, where members discuss topical subjects before updating the workforce. For example, legal services identified that officers were not putting enough detail in statements about the use of handcuffs; this was causing problems with civil claims. The force communicated this to supervisors and standards of detail recorded have since improved.
The force has sufficient resources and ICT systems available that enable it to vet the workforce. These include high-risk posts and contractors. The force was able to demonstrate that where required it sends the relevant notification to the College of Policing to prevent inappropriate candidates re-entering law enforcement. The vetting department provides statistics to the chief officer team. These include analysis of the ethnicity of those vetted. We found that the force was complying with our 2016 vetting recommendation: during fieldwork we found that the force had only eight non-vetted personnel (0.21 percent of the overall workforce).
The PSD has produced ‘60 second standards’ videos for the workforce. So far it has released four, covering business interests, drug and alcohol misuse, abuse of authority for sexual gain and inappropriate notifiable associations. We viewed some of these and found them to be informative and relevant. The head of the PSD also attends student officer training lessons to talk about standards and explain the department’s role within the force.
The force clarifies and reinforces acceptable and unacceptable standards of behaviour. It does this through the force intranet, or a weekly news bulletin. It publishes the outcomes of misconduct hearings, which highlight to the workforce the consequences of adopting poor or inappropriate standards. Once again, the focus is on prevention. The PSD has also established a business integrity panel. Members of the workforce can attend this meeting. This forum gives the wider workforce an insight into the PSD’s activities. Attendees discuss redacted cases to learn more about, and give their views on, how the PSD deals with issues and decisions. Recent cases discussed have included speeding police vehicles and overtime claims.
Humberside Police has a local strategic counter-corruption threat assessment and a local strategic counter-corruption control strategy. Together these meet the force’s need. The assessment recommends that the force counter-corruption unit (CCU) should focus primarily on:
- sexual misconduct;
- controlled substances; and
- disclosure of information.
CCU interventions should be based on a 4P format of pursue, prevent, prepare
We found that those we spoke to during our inspection know how to report inappropriate behaviour. They told us they would contact the PSD through Bad Apple or a supervisor. Bad Apple is the confidential reporting system for the workforce to report internal wrongdoing. It is a significant source of intelligence used by the CCU, which sits within the PSD. Our inspection found that the PSD deals with reports promptly and provides feedback to informants where appropriate. But we did find that some of the workforce does not have confidence in the anonymity of the Bad Apple reporting process. The force’s policy is to support anyone reporting misconduct. This aims to maintain confidence among the workforce in reporting these issues.
The force also has policies on business interests, gratuities and associations. It was able to show us that it monitors these. The workforce generally had awareness of policies but we did find confusion among some members on the value of items they should report as gratuities or gifts. This would benefit from clarification by the force.
Prior to our fieldwork, we carried out some insight work within the PSD and the CCU. During this insight work, we found that the PSD could monitor compliance with decisions made regarding notifiable associations better. This is the responsibility of local commanders and there is no central audit to establish that appropriate monitoring is taking place. However, the force uses early interventions appropriately, and it investigates all criminal allegations fully.
We found that the force doesn’t yet have the capability to monitor all ICT systems and the data contained within them; this presents a risk to the force. The current system of auditing provides a large amount of data that is difficult to analyse, resulting in ineffective searches. The force is aware of both these matters and has plans to address them.
The force has developed effective links with external organisations who support vulnerable victims of crime. The PSD has made contact with domestic abuse groups and care homes. This included providing guidance on what to look for and report in cases of abuse of position.
Of the 57 items of corruption intelligence we reviewed, eight required referring to the Independent Office for Police Conduct (IOPC). We could only establish that the force had referred four of these cases. For the other four cases, we couldn’t find evidence of discussion with the IOPC or any referral documentation. The force should make sure it refers all appropriate to the IOPC, and records this, at the outset.
Humberside Police had submitted a plan to address our 2016 national recommendation regarding the abuse of position for a sexual purpose. The force hasn’t yet fully implemented the plan, due to the outstanding issue regarding the ability to monitor all force systems. The force has noted this on its risk register. Following this year’s inspection, we also consider that there are insufficient resources in the CCU to conduct more proactive work.
The force has provided training and guidance to officers concerning abuse of authority for a sexual purpose. Those we spoke to generally knew about the importance of understanding abuse of authority for a sexual purpose and how to report it or raise it with supervisors. Some of the workforce told us they hadn’t formally received anything about it in terms of training inputs or literature. The force should re-circulate the guidance and ensure the whole workforce is aware of it.Summary for question 2
To what extent does the force treat its workforce with fairness and respect?
This question was not subject to detailed inspection in 2018/19, and our judgment from the 2017 legitimacy inspection has been carried over.